POINIER v. C.I.R.

Nos. 88-1087 to 88-1089.

858 F.2d 917 (1988)

Lois W. POINIER, as Transferee of Helen Wodell Halbach, Appellant, v. COMMISSIONER OF INTERNAL REVENUE. W. Page WODELL, as Transferee of Helen Wodell Halbach, Appellant, v. COMMISSIONER OF INTERNAL REVENUE. ESTATE OF Helen Wodell HALBACH, Deceased, Lois Wodell Poinier, Executrix Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided September 30, 1988.


Attorney(s) appearing for the Case

Geoffrey J. O'Connor (argued), Garden City, N.Y., for appellants.

William S. Rose, Jr., Asst. Atty. Gen., Gary R. Allen, Ann Belanger Durney, Francis M. Allegra (argued), Attys., Tax Div., Dept. of Justice, Washington, D.C., for appellee.

Before GIBBONS, Chief Judge, and SEITZ and HUTCHINSON, Circuit Judges.


OPINION OF THE COURT

GIBBONS, Chief Judge:

Lois W. Poinier, as transferee of Helen W. Halbach, W. Page Wodell, as transferee of Helen W. Halbach, and Louis W. Poinier, executrix of the estate of Helen W. Halbach, appeal from a Tax Court decision 1) that Helen W. Halbach made a transfer subject to a gift tax, 2) that her children are liable as donee transferees, and 3) that her children are liable for interest, beyond the value of the gift, accrued since...

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